Case Summary (G.R. No. 127382)
Antecedents
The petitioners filed their complaint on August 11, 1982, asserting they are the absolute owners of a 2.5-hectare parcel of land (Lot No. 3533-A) and have been in possession for over thirty-five years. They claimed to have purchased the land from Lucia Vda. de Marbella, supported by a Deed of Sale dated August 23, 1947. Discovering that Victor Caballero claimed ownership and was offering the property for sale, the petitioners sought legal redress. Following the death of Dr. Jesus SeriAa on August 6, 1983, his children were substituted as parties to the case.
Respondents' Position
In their answer, the respondents asserted ownership based on a longer history of possession, claiming that the disputed land was part of Cadastral Lot No. 3533 inherited from Eustaquio Caballero, and presented a tax declaration (No. 2442) for the property despite records being destroyed during the war. They contested the petitioners’ ownership and highlighted discrepancies in the ownership documents, specifically regarding the land’s boundaries and area.
Regional Trial Court Judgment
The RTC ruled in favor of the respondents on January 21, 1992, dismissing the petitioners’ complaint. The RTC found that the petitioners failed to conclusively demonstrate that the land in their possession was the same as that claimed by them, particularly due to inconsistencies in the boundaries and area described in the various declarations and deeds.
Court of Appeals Affirmation
Upon appeal, the CA upheld the RTC decision, leading to further petition for review by the petitioners. They raised two main issues: (1) whether they established the identity of the land; and (2) whether the concept of acquisitive prescription should be applied in their favor.
Issues on Land Identity
The Supreme Court reiterated that the determination of factual identities such as property boundaries falls outside the jurisdiction of a petition for review on certiorari, which focuses on errors of law. It pointed out that the CA’s affirmation of the RTC's factual findings must be based on substantial evidence, and the CA concluded that the petitioners failed to demonstrate that the land in dispute is the same as that referenced in their ownership claims.
Examination of Boundaries and Evidence
The discrepancies cited included different boundary owners listed, an inconsistency in the area (2.5 hectares claimed versus the 5 hectares in the Deed of Sale), and conflicting locations provided in the documentation. The CA noted that such inconsistencies are paramount in disputes of land ownership, as the one claiming ownership must demonstrate clearly the identity of the property, which the petitioners failed to accomplish.
Acquisitive Prescripti
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Case Overview
- The case involves a petition for review on certiorari of the Decision of the Court of Appeals dated August 23, 1996.
- The main issue centers around the dismissal of the complaint for quieting of title, recovery of possession, and damages filed by the petitioners against the respondents by the Regional Trial Court of Misamis Oriental.
- The petitioners include the heirs of Dr. Jesus SeriAa, who claimed ownership of a parcel of land, while the respondents asserted their ownership based on historical possession and tax declarations.
Antecedents
- On August 11, 1982, Dr. Jesus SeriAa and his wife filed a complaint claiming ownership of a 2.5-hectare parcel of land located in Mantadiao, Opol, Misamis Oriental.
- The petitioners alleged a continuous and uninterrupted possession of 35 years, and based their ownership on a Deed of Sale dated August 23, 1947, from Lucia Vda. de Marbella.
- After Dr. SeriAa's death in 1983, his children continued the case, asserting their rights over the property.
- The respondents, led by Victor Caballero, claimed ownership asserting their rights through historical possession and tax declarations.
Petitioners’ Claims
- The petitioners contended they were the absolute owners of the land in question and provided evidence of continuous possession and tax payments since 1947.
- They alleged that respondent Caballero had been unlawfully claiming ownership and attempting to sell or mortgage the land.
- The petitioners presented the Deed of Sale and tax declarations as evidence of their ownership.
Respondents’ Defense
- The respondents claimed that the disputed property had been